Finding 524108 (2024-005)

Significant Deficiency Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-02-20

AI Summary

  • Core Issue: CAP submitted reimbursement requests that exceeded actual expenditures by $3,222 due to inadequate review and reconciliation processes.
  • Impacted Requirements: Reimbursement requests must be supported by documentation and reflect costs paid prior to the request date.
  • Recommended Follow-up: CAP should enhance internal controls and procedures for reimbursement requests to ensure accuracy and compliance.

Finding Text

Significant Deficiency over Internal Control 2024-005 Cash Management Program: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Assistance Listing No: 93.224 County Recipient: Community Action Partnership of Natrona County Federal Agency: Department of Health and Human Services Grant year: 2022 Federal Award Identification: Unknown Applicable Pass-through Entity: None Criteria When non-federal entities are funded under the reimbursement method, expenditures included in reimbursement requests should have supporting documentation and the entity should have paid for the costs for which the reimbursement is requested prior to the date of the reimbursement request. Condition Community Action Partnership of Natrona County (CAP) submitted reimbursement requests in excess of actual expenditures. Cause Due to turnover in grant management, processes that had previously existed were overlooked. A reconciliation of grant expenditures to the amounts requested for reimbursement was not performed resulting in reimbursements that were greater than the actual grant expenditures Effect or potential effect Without adequate review and reconciliations of reimbursement requests, an entity may submit inaccurate expenditure reimbursement requests. Questioned Cost None Context We tested 20 out of 31 reimbursement requests submitted during the grant period by comparing each reimbursement request to the actual expenditures in the CAP general ledger. Additionally, we reconciled total grant reimbursements to total grant expenditures. We noted that total grant reimbursement requests exceeded the total grant expenditures by $3,222. Identification as a Repeat Finding Repeat finding of 2023-003 Recommendation We recommend CAP review its policies and procedures related to the internal controls over reimbursement requests to assure reimbursement requests have supporting documentation and reconcile to actual expenditures incurred. Views of Responsible Officials Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. See Corrective Action Plan

Corrective Action Plan

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

Categories

Cash Management Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 524106 2024-004
    Material Weakness
  • 524107 2024-004
    Material Weakness
  • 524109 2024-004
    Material Weakness
  • 524110 2024-004
    Material Weakness
  • 1100548 2024-004
    Material Weakness
  • 1100549 2024-004
    Material Weakness
  • 1100550 2024-005
    Significant Deficiency Repeat
  • 1100551 2024-004
    Material Weakness
  • 1100552 2024-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.08M
93.569 Community Services Block Grant $704,243
21.032 Local Assistance and Tribal Consistency Fund $419,295
93.224 Covid-19 - Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $318,421
93.069 Public Health Emergency Preparedness $238,000
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $116,066
93.145 Hiv-Related Training and Technical Assistance $99,753
97.067 Homeland Security Grant Program $99,115
93.569 Covid-19 - Community Service Block Grant $91,580
93.268 Covid-19 - Immunization Cooperative Agreements $84,398
93.558 Temporary Assistance for Needy Families $69,966
93.959 Block Grants for Prevention and Treatment of Substance Abuse $69,943
14.267 Continuum of Care Program $60,290
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $53,586
95.001 High Intensity Drug Trafficking Areas Program $44,368
14.231 Covid-19 - Emergency Solutions Grant Program $41,471
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $41,356
93.387 National and State Tobacco Control Program $23,883
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $17,562
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $11,520
97.012 Boating Safety Financial Assistance $7,835
16.607 Bulletproof Vest Partnership Program $6,653
20.600 State and Community Highway Safety $5,884
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $3,391
20.616 National Priority Safety Programs $1,037